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FATCA Registration System Updates

The following summarizes the changes to the FATCA Registration System since its launch.  The Foreign Account Tax Compliance Act (FATCA) User Guide has been updated to include these changes:

July 2018

The IRS has updated the Foreign Account Tax Compliance Act (FATCA) Registration System to incorporate the certification of pre-existing accounts (COPA) and periodic certification process.

The Registration System updates include the following: 

New option to submit a certification:

  • Complete and submit COPA and periodic certifications

Updates to account home page:

  • View COPA and periodic certification summary information
  • View and print submitted certifications

Updates to Registration Form

  • Updated list of FATCA classifications
  • Review certification information in lead FI's member table

All FATCA registered entities are advised to login to update their FATCA classification. Entities that have a certification requirement are required to update their FATCA classification. Entities that do not have a certification requirement should update their FATCA classification in order to avoid inapplicable certification related notices in the future. Entities can update their FATCA classification by updating their response to question 4 in the registration or by answering the question during the certification process.

The table below provides a general overview of the types of entities that are required to certify and which certification(s) they must submit.  For more specific guidance, see Section 8 of Revenue Procedure 2017-16, the Treasury regulations, or an applicable intergovernmental agreement (IGA).
 

Financial Institution's FATCA Classification in its Country/Jurisdiction of Tax Residence Certification Required?
  COPA Periodic
Participating FFI, including a Reporting Financial Institution under a Model 2 IGA *, ** Yes Yes
Registered Deemed-Compliant FFI that is a Local FFI Yes Yes
Registered Deemed-Compliant FFI that is a Non-Reporting Member of a PFFI Group No Yes
Registered Deemed-Compliant FFI that is a Qualified Collective Investment Vehicle No Yes
Registered Deemed-Compliant FFI that is a Qualified Credit Card Issuer or Servicer No Yes
Registered Deemed-Compliant FFI that is a Restricted Fund Yes Yes
Reporting Financial Institution under a Model 1 IGA * No, except on behalf of branches operating outside of Model 1 jurisdictions (other than related branches) No, except on behalf of branches operating outside of Model 1 jurisdictions (other than related branches)
Direct Reporting NFFE No Yes
Sponsoring Entity of Sponsored Direct Reporting NFFEs No Yes
Sponsoring Entity of Sponsored FFIs Yes Yes
Sponsoring Entity of Sponsored FFIs and Sponsored Direct Reporting NFFEs Yes, on behalf of Sponsored FFIs only Yes
Trustee of a Trustee-Documented Trust No Yes ***
U.S. Financial Institution * No No

 

*Compliance FIs may make the COPA and periodic certifications on behalf of electing FFIs that are part of the compliance FI’s consolidated compliance program.  A compliance FI may have one of the following three FATCA classifications: (1) Participating FFI, including a Reporting Financial Institution under a Model 2 IGA; (2) Reporting Financial Institution under a Model 1 IGA; or (3) U.S. Financial Institution.

** A participating FFI that is an electing FFI of a consolidated compliance group will be included in the certification of the compliance FI.

*** A periodic certification of compliance is required only for a Trustee-Documented Trust that is subject to a Model 2 IGA.

Note:  The registration system will suggest the certification(s) for an entity based on its FATCA classification in question 4 of the registration system.  Therefore, even entities that do not have a certification requirement should update their FATCA classification to avoid inapplicable certification-related notices in the future.

Entities should monitor their message board for certification notifications and review the updated  FATCA Online Registration User Guide for detailed certification instructions and information. If you are the Responsible Officer (RO) of an entity that is required to certify, but the certification link does not appear on your home page, please contact the IRS E-Help Desk for assistance.

June 2017

The FATCA FFI Registration system was updated to include the ability for FFIs to renew their agreement with the IRS in order to maintain approved status on the FFI List. The system sends email notifications to FIs when the renewal open period begins. From the FATCA Registration home page link of “Renew FFI Agreement,” the FI select a determination whether it must renew its FFI agreement. A table of guidelines is provided to assist in this determination (example below). Once the determination is made, the system enables the FI to update their registration information and submit to renew their FFI agreement.  
 

Financial Institution’s FATCA Classification in its Country/ Jurisdiction of Tax Residence Type of Entity FFI Agreement Renewal Required?
Participating Financial Institution not covered by an IGA; or a Reporting Financial Institution under a Model 2 IGA Participating FFI not covered by an IGA Yes
Reporting Model 2 FFI Yes
Registered Deemed-Compliant Financial Institution (including a Reporting Financial Institution under a Model 1 IGA) Reporting Model 1 FFI operating branches outside of Model 1 jurisdictions Yes, on behalf of branches operating outside of Model 1 jurisdictions (other than related branches*)
Reporting Model 1 FFI that is not operating branches outside of Model 1 jurisdictions; No
Registered deemed-compliant FFI (regardless of location) No
None of the above Sponsoring entity No
Direct reporting NFFE No
Trustee of Trustee-Documented Trust No


*Related branches means branches treated as nonparticipating FFIs under Article 4(5) of the Model 1 IGA.

FIs who select they are not required to renew, do not need to take any further action with respect to its registration to remain in approved status on the IRS FFI List.

Further updates to the system included:

  • The classification option of Limited is no longer available for new FI applicants or for renewing FIs.
  • The United States government computer system warning banner is included at log in.
  • The attempts to unsuccessfully login is now reduced to three.

December 2016

The QI/WP/WT questions have been removed from the FATCA Registration system due to the future release of a new system, The Qualified Intermediary (QI), Withholding Foreign Partnership (WP) and Withholding Foreign Trust (WT) Application and Account Management System; also known as the QI System.

The FATCA Online Registration System will no longer display Part 3 questions in the application nor request whether a branch is covered by a QI agreement. Part 3 pertains to financial institutions having a QI, WP or WT withholding agreement with the IRS. Previously, entities could renew their QI, WP or WT agreement within the FATCA Online Registration System but this will no longer be the case. Within the FATCA Online Registration System, financial institutions will no longer request users to:

  • Identify legal name change since the effective date of its most recent QI, WP, or WT agreement
  • Identify the QI, WP or WT Responsible Party
  • Identify any private arrangement intermediary (PAI) agreements that are effective
  • Identify if the branch is currently covered by a QI agreement, does the Financial Institution intend to maintain QI status for that branch

The new QI System will focus on these items and all the information related to the QI, WP, and WT agreement. Existing QIs, WPs, and WTs with a FATCA Registration account and future QIs, WPs and WTs will manage and maintain that information solely in the QI System.

November 2015

New Registration Questions
Two new registration questions:

    • Question 3B – Country Tax ID - See Section 6.1 for more information
    • Questions 13A and 13B – Common Parent Entity Information - See Section 3.2.3 for more information

Questions are renumbered beginning at Question 13

Edit Registration by Part

    • FIs in various statuses can edit their registration from the beginning of Part 1, Part 2, or Part 3 of the online registration, without having to page through the entire registration to make an update using the “Registration – Edit” links.
    • “My Information” links (ex: My Information (Part 1) – Review) have been replaced by the “Registration - Edit” links. To view registration information, use the Print Registration PDF link on the home page.

“Country” to “Country/Jurisdiction”
In the FATCA Online Registration System, references to “Country” changed to “Country/Jurisdiction.”

Delete Registration Warnings
A warning will display if the answer to Question 6 or Question 7 is changed from Yes to No. This helps to prevent unintentionally deleting registration information.

Change FI Type or Transfer into an Expanded Affiliated Group (EAG)
Certain FIs can change their FI type or transfer to an EAG.

Add and Manage Sponsored Entities and Sponsored Subsidiary Branches
Sponsoring entities can add, edit, delete, sponsored entities and sponsored subsidiary branches. Multiple sponsored entities and sponsored subsidiary branches can be added at once using a file upload.

Updates to GIIN Composition Document
Includes sponsored entity and sponsored subsidiary branch information.

Updates to Help Content
Existing help content and new help content can be found in this user guide and on the FATCA Online Registration system.

Accessibility Information for the FATCA Online Registration System
The Accessibility Guide provides users a link to information and resources on assistive technology available for FATCA Online Registration System.

October 2014

Updates to FI Legal Name Fields (Questions 2, 12, 13 and 15 of the Registration)

    • Expanded length of FI legal name fields from 40 characters to 150 characters.
    • Addition of allowed special characters: FI legal name field can now accept brackets [], curly brackets {} and parentheses ().

Printing Registration Form

    • FIs can print or download a PDF file of their full registration information from their homepage if the account status is one of the following: Registration Submitted, Approved or Limited Conditional.

Point of Contact (POC) Information downloadable files

    • Point of Contact (POC) information from question 11B, can be downloaded in PDF or CSV format from the Registration once information is entered. This file will also contain the Responsible Officer Information entered in question 10.

    • A link to download the POC information is available on the homepage as long as information is entered in question 11b.

PAI Contract information downloadable files

    • PAI Contract Information from question 15 can be downloaded in PDF or CSV format from the registration once information is entered.

    • A link to download the PAI contract information is available on the homepage as long as information is entered in question 15.

Branch Table downloadable files

    • Formatting added to branch PDF file, including header information about the FI.

    • Branch tables can now be downloaded in CSV format.

Member Table downloadable files

    • Formatting added to member PDF files, including header information about the FI.

    • Member tables can now be downloaded in CSV format.

FATCA Registration Login

    • FATCA IDs are no longer case sensitive when logging in. FIs can enter their FATCA ID In either upper case or lower case letters.